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Archive December 2019

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Submit Comments to CMS: Scope of Practice

Yesterday, the Centers for Medicare and Medicaid Services (CMS) announced that it is seeking additional feedback regarding elimination of Medicare regulations that require stricter supervision compared to state scope of practice laws, or that limit health professionals from practicing at the top of their license.

CMS is seeking this feedback in response to the President’s Executive Order (EO) on Protecting and Improving Medicare for ...

Federal Affairs News Brief - December

Federal Affairs News Brief - December 2019

PDPM nad PDGM Updates

As part of overall efforts to move Medicare payment away from fee for service and toward a structure that holds providers accountable for patient outcomes and costs, the Centers for Medicare and Medicaid Services (CMS) has made significant changes to the skilled nursing facility (SNF) and home health payment systems. The SNF Patient-Driven Payment Model (PDPM) began October 1, and the Home Health Patient-Driven Groupings Model (PDGM) begins January 1, 2020.
Both PDPM and PDGM align payment with patient characteristics, conditions, and needs, and eliminate the connection between reimbursement and the volume of therapy services provided—time spent and number of visits. This change makes it ever more important to show the value and cost-effectiveness of physical therapist services within SNFs and home health care. At the same time, what doesn't change is the coverage criteria or documentation requirements associated with the skilled therapy service coverage under PDPM and PDGM. More important, there is no change to the care needs of patients, which should be the primary driver of care decisions, including the type, duration, and intensity of skilled therapies.
APTA has been working to keep the profession up-to-date with the evolution of the PDPM and PDGM through our news and social media outlets, webinars, phone-in sessions, and other free, open access resources on the APTA SNF and Home Health Payment Models website. Three of the APTA Sections - Home Health Section, Academy of Geriatric Physical Therapy, and HPA the Catalyst, have a number of other resources on their respective websites to help clinicians prepare and thrive in these new payment models.
APTA also has been actively communicating with the press to highlight concerns surrounding the industry’s implementation of PDPM and potential inappropriate behaviors. Recent articles include: The new payment models do not change the value of physical therapy services or patient needs. PDPM and PDGM expect rehabilitation professionals will continue to furnish high-quality therapy services that are reasonable and necessary. APTA maintains an ongoing dialogue with CMS and we are sharing with them the feedback we’re receiving from physical therapists and physical therapist assistants regarding their experiences with PDPM and PDGM. APTA will continue to carefully monitor implementation of the models and advocate for appropriate changes as CMS evaluates the systems during the first year of implementation.
Questions? Comments? Concerns? All physical therapists and physical therapist assistants (members and non-members) are encouraged to share their PDPM and PDGM experiences at advocacy@apta.org. Also, if you’d like to join the Post-Acute Care online community (Hub), please contact Kara Gainer at karagainer@apta.org.
 
Kara R. Gainer, JD
Director of Regulatory Affairs
American Physical Therapy Association
1111 North Fairfax Street
Alexandria, VA 22314
703/706-8547

PAC Q&A

 
If you attended this year’s VPTA conference, you likely noticed the presence of the VPTA Political Action Committee Chair, Dr. Andy Tatom, PT, DPT, OSC.  As chair of the PAC, Dr. Tatom works with the legislative chair, the VPTA lobbyist, and the executive board to plan and coordinate PAC events. With recent and ongoing legislation impacting the physical therapy field, I decided to ask Dr. Tatom to tell me a bit more about the VPTA-PAC. 
  • What is your elevator speech pitch for the VPTA-PAC? 
  • The PAC is like an insurance policy to help protect the practice of Physical Therapy in Virginia. The PAC donations opens access to legislators so we can discuss our legislative agenda with them.

What is the role of the VPTA-PAC and how does the VPTA-PAC differ from the APTA PAC?
The VPTA-PAC deals with Virginia issues where The APTA-PAC deals with national issues. One difference is the corporations can give it the VPTA-PAC but not to the APTA-PAC
What are some recent accomplishments of the VPTA PAC?
The VPTA-PAC just raised over $10,500 at our most recent event and at the Fall Conference.

What are some upcoming priorities of the VPTA PAC and how much money would the VPTA-PAC need to raise in order to accomplish some of those priorities and goals?
We continue to support the VPTA legislative agenda.  If the VPTA is going to push for unfettered direct access in the near future we will need to raise several hundred thousand dollars to support this effort.

Why should people donate to the VPTA PAC?
As I said before the VPTA PAC has supported many initiatives in the past: direct access, term protection, dry needling, workers comp fee schedule, practice compact and practice encroachment from ATCs and massage therapists. If we don’t stand up for ourselves who will? The VPTA PAC stands for us.
 
What is one fun fact many people may not know about the VPTA PAC?
The PAC is made up of Virginia PTs and PTAs and we are some of the most fun people in Virginia!

Anything else that you would like to add about the VPTA PAC?
Don’t expect someone else will stand up for you. The VPTA-PAC helps all PTs and PTAs in Virginia regardless of practice setting. Everyone needs to help because if you don’t someone will take more of our proactive away from us. So give when you are asked--WE NEED YOU!
 
Thank you Dr. Tatom for taking your time to answer questions about the VPTA PAC!

If you would like to donate to the VPTA PAC, you may do so here: https://secure.membershipsoftware.org/vptasecure/donation_pay.asp
                                                                                                           
Entry by Jordan Tucker
 

 

Lobby Day 2020

VPTA is organizing Lobby Day and would like to include 30 members to join on Wednesday, January 22 from 7:30 am until noon in Richmond, Virginia. If you have interest, please register. One of the questions you'll be required to answer during registration is to identify your legislators. We use this information to form the groups. If you are not sure who your legislators are, you can look them up here. Thank you for your interest in state advocacy!

Instructors/Program Chairs: You can register yourself and your three students here.

Students: If you are interested in attending Lobby Day, talk to your program chair and share 
this link with them.

2020 Physician Fee Schedule Final Rule

On November 1, 2019, the Centers for Medicare and Medicaid Services released the 2020 Physician Fee Schedule/Quality Payment Program final rule. The rule includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule effective on or after January 1, 2020.

Within the rule, among numerous other policies, CMS finalized a policy regarding application of the new PTA and OTA modifiers on outpatient therapy claims beginning in 2020. As you may know, beginning January 1, 2020, outpatient therapy providers are required to affix a modifier the claim to denote when outpatient therapy is furnished in whole or part by PTA or OTA. Then, beginning on January 1, 2022, payment for outpatient therapy services provided by PTA or OTA will be at 85% of the physician fee schedule. In response to APTA’s advocacy efforts, CMS adopted all of APTA’s recommended improvements to the policy. Scenarios outlining how to use the new modifiers will be posted to the CMS website in the near future.

CMS also finalized its proposal to adopt increases to the values of the office/outpatient E/M codes in 2021, which requires CMS to make redistributive negative adjustments across specialties to maintain budget neutrality under the Medicare physician fee schedule. Under the plan, physical therapy/occupational therapy could see reductions to CPT code valuations that may result in an estimated 8% decrease in payment in 2021. In total, 36 specialties are facing reimbursement reductions in 2021.

Other policies to be aware of:

  • CY 2020 KX modifier threshold amount: $2,080 for PT and SLP services combined and $2,080 for OT services.
  • Trigger point dry needling codes (20560 and 20561): Although CMS finalized the work and practice expense RVUs for these codes, CMS stated in the final rule that these dry needling codes are non-covered Medicare services in 2020.
  • CMS adopted new regulations that permit CMS to revoke or deny a physician or other eligible professional’s Medicare enrollment when such professional’s actions result in patient harm.
  • CMS finalized changes to the PT/OT specialty measure set for MIPS in 2020.
  • CMS will continue to reweight the Promoting Interoperability category for physical therapists in 2020.

APTA is in the process of determining next steps to respond to the anticipated Medicare cuts in 2021 and are exploring all potential policy solutions and strategies. We will leverage every possible opportunity to change this flawed policy. We also are reaching out to our partners as well as the other impacted professions to set up calls and discuss strategy and how we might work together moving forward.

Questions regarding the 2020 Medicare Physician Fee Schedule final rule should be directed to advocacy@apta.org.

 

Kara R. Gainer, JD

Director of Regulatory Affairs

American Physical Therapy Association

1111 North Fairfax Street

Alexandria, VA 22314

703/706-8547

APTA.org

Attachments:
2020 PFS Final Rule Detailed Summary.pdf (380.8 KB)

Happy Physical Therapy Month

Along with all the daily hard work with patients and students, last month was busy with letter writing to CMS so we could continue to advocate for our profession and our patients! 

So, in celebration of National Physical Therapy Month, something a little lighter.  Enjoy some fun and interesting facts about physical therapy:

 

  1. Worldwide, there are over 1.5 million physical therapists. 1
  2. Physical therapist assistants celebrated their 50th birthday this year!  The profession graduated its first 15 students in 1969 from schools in Florida and Minnesota.  2
  3. There are currently 250 accredited PT programs and 371 accredited PTA programs with a total of enrolled 47,188 students.  3
  4. The APTA began in 1921 and was originally called the American Women’s Physical Therapeutic Association.  This name changed in 1922 to the American Physiotherapy Association and men were then admitted.  The name changed again in the late 1940’s to its current name.  The first code of ethics was introduced by the APTA in the 1930s. 4
  5. Did you know that wheelchairs have been used since the 6th century AD?  The first self-propelled wheelchair was invented in 1655 by a clockmaker with paraplegia. 5
  6. September 9th is World Physical Therapy Day and October 12th, 2019 was Global PT Day of Service.   Check out the map here to see all the great work which was done by PTs and PTAs across the globe!  If you have any photos of what you did to celebrate PT Day of Service, please make sure to share to Facebook or send them by email to vpta@vpta.org.

 

Happy Physical Therapy Month!!  Celebrate all the great work you do year-round!

 

References:

  1. World Confederation for Physical Therapy (2016).  WCPT country profile: United States.  Retrieved from https://www.wcpt.org/sites/wcpt.org/files/files/cds/Infographic4-2017.pdf
  2. Wojciechowski, M. (2019).  Celebrating a milestone: 50 years of PTAs.  Retrieved from https://www.apta.org/PTinMotion/2019/2/Feature/Celebrating50Years/
  3. CAPTE (2018).  Welcome to CAPTE: Quick facts.  Retrieved from http://www.capteonline.org/home.aspx
  4. APTA (2017).  APTA history.  Retrieved from https://www.apta.org/History/
  5. Nias, K. (2019).  History of the wheelchair.  Retrieved from https://blog.sciencemuseum.org.uk/history-of-the-wheelchair/

https://lh4.googleusercontent.com/KeFwnQFc1WKq6ZxHbo58Vn-2oE_jadLNf_BVhUnAzebWPstzJj2keTHJoWutRQVbMQSCrY64ak5va7drUwa8LuY97RKONagJNVEEhpSoMVfhKcb92WIGCjxNNf-5OQ

2019 Election Results

Many thanks to those who voted in the 2019 elections and to those who ran on the ballot. Here are the election results.

Where Things Stand, What APTA's Doing: Fee Schedule, SNF, and HH Rules From CMS

Please see this article published on PTNow for more information.

Update on Home Health and Skilled Nursing Facility Payment System Changes

Greetings,

As part of overall efforts to move Medicare payment away from fee for service and toward a structure that holds providers accountable for patient outcomes and costs, the Centers for Medicare and Medicaid Services (CMS) has made significant changes to the home health and skilled nursing facility (SNF) payment systems. The SNF Patient-Driven Payment Model (PDPM) began October 1 (the start of fiscal year 2020), and the Home Health Patient-Driven Groupings Model (PDGM) begins January 1, 2020.

APTA advocated to CMS on behalf of the physical therapy profession and our patients when the plans for payment system changes were first presented in 2017. Since that time, we’ve submitted comments and met in person with CMS representatives and federal legislators, both as an individual organization and as part of therapy organization coalitions. APTA strongly advocated for the inclusion of safeguards in PDPM and PDGM, including limitations on the amount of group and concurrent therapy that can be delivered (PDPM), and mechanisms to allow CMS to monitor and track therapy utilization and changes in patient outcomes.

Both of these payment systems align payment with patient characteristics, conditions, and needs, and eliminate the connection between reimbursement and the volume of therapy services provided—time spent and number of visits. This change makes it ever more important to show the value and cost-effectiveness of physical therapist services within SNFs and home health care. At the same time, what doesn't change is the coverage criteria or documentation requirements associated with the skilled therapy service coverage under PDPM and PDGM. More important, there is no change to the care needs of SNF and home health patients, which should be the primary driver of care decisions, including the type, duration, and intensity of skilled therapies. That some providers may choose to reduce PT and PTA staff reflects poorly on the industry's commitment to patient accessibility and availability, safety, and quality of care.

APTA has been working to keep the profession up-to-date with the evolution of the PDPM and PDGM through our news and social media outlets, webinars, phone-in sessions, and free, open access resources on the APTA SNF and Home Health Payment Models website. We are committed to helping the physical therapy profession better understand PDPM and PDGM, and educating employers and other stakeholders in developing responsible approaches to these new systems.

APTA created these brief summaries to give you the facts about the impact of the 2 new payment models in a format you can share with others.

Three of the APTA Sections - Home Health Section, Academy of Geriatric Physical Therapy, and HPA the Catalyst, have a number of other resources on their respective websites to help clinicians prepare and thrive in these new payment models. APTA also has the APTA Center for Integrity in Practice, which is a product of the American Physical Therapy Association's Integrity in Practice Campaign. It is designed specifically for physical therapists, physical therapist assistants, educators, and leaders to better understand fraud and abuse in health care and the impact they have on the profession of physical therapy, on individual clinicians, and on their freedom to practice. The Center for Integrity in Practice includes Upholding Integrity, Reducing Risk, and Best Practices resources.

APTA, along with ASHA, and AOTA, issued a joint statement on October 2, (attached), responding to the concerns surrounding PDPM implementation; APTA President Sharon Dunn issued a statement on the same date, stating: PDPM changed Medicare payment methodology for SNFs on Oct 1. It did not change the value of physical therapy services or patient needs. Reducing PT and PTA staff 48 hours into this model reflects poorly on the commitment to patient access and quality of care. And CMS is watching. APTA also has been actively communicating with the press to highlight concerns surrounding the industry’s implementation of PPDM and potential inappropriate behaviors. Recent articles include:

The new payment models do not change the value of physical therapy services or patient needs. PDPM and PDGM expect rehabilitation professionals will continue to furnish high-quality therapy services that are reasonable and necessary. CMS is closely tracking outcomes and therapy utilization, and actions such as mandating group therapy and inappropriately limiting medically necessary therapy services will draw the attention of the agency. APTA maintains an ongoing dialogue with CMS and we are sharing with them the feedback we’re receiving from physical therapists and physical therapist assistants regarding problematic reactions to PDPM. APTA will continue to carefully monitor implementation of the PDPM and advocate for appropriate changes as CMS evaluates the system during the first year of implementation.

Questions? Comments? Concerns? All physical therapists and physical therapist assistants are encouraged to reach out to APTA at advocacy@apta.org.

Kara R. Gainer, JD

Director of Regulatory Affairs

American Physical Therapy Association

1111 North Fairfax Street

Alexandria, VA 22314

703/706-8547

APTA.org

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